Federal Communications Commission	DA 21-723



DA 21-723
Released:  June 21, 2021

WIRELESS TELECOMMUNICATIONS BUREAU AND OFFICE OF ENGINEERING AND TECHNOLOGY EXTEND THE CONDITIONAL AUTHORIZATION OF KEY BRIDGE’S ENVIRONMENTAL SENSING CAPABILITY 
GN Docket No. 15-319

On July 14, 2020, the Wireless Telecommunications Bureau (WTB) and the Office of Engineering and Technology (OET) (collectively, WTB/OET) of the Federal Communications Commission (Commission or FCC) approved Consistent with the 2015 Report and Order and as established in the First Wave Proposal Public Notice, all ESC operators must complete a two-stage review process prior to final certification.  See Amendment of the Commission’s Rules with Regard to commercial Operations in the 3550-3650 MHz Band, GN Docket No. 12-354, Report and Order, 30 FCC Rcd 3959, 4064-66, paras. 359-366 (WTB/OET 2015) (2015 Report and Order); Wireless Telecommunications Bureau and Office of Engineering and Technology Establish Procedure and Deadline for Filing Spectrum Access System (SAS) Administrator(s) and Environmental Sensing Capability (ESC) Operator(s) Applications, GN Docket No. 15-319, Public Notice, 30 FCC Rcd 14170, 14174-77 (WTB/OET 2015) (First Wave Proposal Public Notice).  
 Key Bridge Wireless LLC’s (Key Bridge) Environmental Sensing Capability (ESC) for commercial operation. Wireless Telecommunications Bureau and Office of Engineering and Technology Announce the Approval of an Additional Environmental Sensing Capability for the 3.5 GHz Band, GN Docket No. 15-319, Public Notice, 35 FCC Rcd 7001 (WTB/OET 2020) (Key Bridge ESC Approval PN).  
  Key Bridge’s ESC approval was conditioned on successful resubmission and laboratory testing of the latest version of its ESC software before December 31, 2020. Id. at 7003 (“As early as practicable, but no later than December 31, 2020, Key Bridge must resubmit its ESC running software version 1.1.0 to ITS for retesting.  Following, completion of its ESC retesting, Key Bridge must submit a report to the Commission in GN Docket No. 15-319 detailing the results of such retesting.  If Key Bridge’s ESC does not pass the required tests, it must immediately cease operation of its ESC and all associated sensors.”).
  On December 21, 2020, WTB/OET extended the deadline for Key Bridge to retest its ESC software to June 30, 2021. Wireless Telecommunications Bureau and Office of Engineering and Technology Extend the Conditional Authorization of Key Bridge’s Environmental Sensing Capability, GN Docket No. 15-319, Public Notice, 35 FCC Rcd 14684 (WTB/OET 2020); see also Letter from Jesse Caulfield, CEO, Key Bridge Wireless LLC, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed Dec. 1, 2020) (requesting a six-month extension of the retesting deadline due to inability to access the NTIA-ITS lab while COVID-19 access restrictions are in place).
  On June 10, 2021, Key Bridge submitted a letter requesting a further six-month extension of the retesting deadline. See Letter from Jesse Caulfield, CEO, Key Bridge Wireless LLC, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 15-319 (filed June 10, 2021).
  Key Bridge asserted that, despite ongoing good faith efforts, as a result of access restrictions caused by the ongoing COVID-19 pandemic, Key Bridge has been unable to coordinate access to the National Telecommunications and Information Administration’s Institute for Telecommunication Sciences (NTIA-ITS) lab to retest its ESC capabilities. Id.

Since Key Bridge has been unable to access the NTIA-ITS facilities due to circumstances beyond its control arising directly from the ongoing COVID-19 pandemic, we find that there is good cause to extend the deadline for Key Bridge to retest its ESC software. See 47 CFR §§ 0.241(j) and 0.331(f).
  Therefore, as early as practicable, but no later than December 31, 2021, Key Bridge must resubmit its ESC running software version 1.1.0 to NTIA-ITS for retesting.  Following completion of its ESC retesting, Key Bridge must submit a report in GN Docket No. 15-319 detailing the results of such retesting.  If Key Bridge’s ESC does not pass the required tests, it must immediately cease operation of its ESC and all associated sensors. 
By the Acting Chief, Wireless Telecommunications Bureau, and the Acting Chief, Office of Engineering and Technology.  
- FCC -




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